Blood Niobium - Header
DUARTE FAMILY VS CMOC CASE (HKEX: 3993)
PROTOCOL: BLOOD-NB-2026

DOSSIER BLOOD NIOBIUM

A Chinese mining company, billions in niobium — and an elderly woman who cannot afford antibiotics.

Evidence Board - CMOC Case
EVIDENCE BOARD. BOA VISTA MINE. CATALÃO/BRAZIL.

Glória Duarte cannot investigate. But you can.

Glória Duarte cannot alert the world. But you can.

Daily Count Real-time update
Niobium extracted — CMOC 0 metric tons
Accumulated extraction
since Jan/2016
10,024 metric tons per year leave the Boa Vista Mine in Catalão (GO) — 24h, 365 days, non-stop. Source: CMOC Annual Report 2024 · HKEX 3993.HK
Revenue — 2026 0 since 01/Jan/2026
Estimated CMOC
niobium revenue
US$ 300 million per year in niobium revenue — while Glória Duarte, 81, widow and blind, receives US$ 180 per month — US$ 2,160 per year. Conservative estimate · Sources: CMOC 2022–2024
Days without response — CMOC 0 days of silence
Silêncio desde
30/03/2015
The 1st extrajudicial notice was delivered on March 30, 2015. To this day, no response from CMOC. 1st documented extrajudicial notice: 03/30/2015
CLASSIFIED — LEVEL 5 — CRITICAL
Section 01

The Case: Defer Until She Dies?

IDENTIFICATION
BLOOD NIOBIUM — From local case to global action.

Blood Niobium is an independent platform that reveals the niobium case at Mina Boa Vista in Catalão, Brazil, through a dossier. The Blood Niobium dossier — structured, verifiable, distributable — transforms a local human rights violation case into an international accountability protocol.

Its goal is to bring international visibility to a concrete human rights violation involving an elderly Brazilian woman in extreme vulnerability, associated with the extraction of a strategic mineral: niobium.

Three simultaneous functions:
Verifiable evidence framework

Each claim has a traceable primary source: lawsuits, CMOC reports (HKEX: 3993), death certificates, published international standards.

Critical analysis protocol

Mapping of legal, accounting, regulatory and humanitarian violations — in the language of those who have the power to respond.

Transnational accountability tool

Documentary guides on violations and risks, distributable to every sphere of decision: Auditors, Regulators, Shareholders, Investors, Certification Agencies, Clients, NGOs, Press, Governments.

From local to global ↗
THE CASE
The case at the center of the dossier.
ACTIVE CASE

GLÓRIA DUARTE VS. CMOC

HKEX: 3993

At the center of this case is Glória Duarte — 81 years old, blind, widowed, and co-owner of the land where CMOC (HKEX: 3993) extracts billions of dollars in niobium.

Glória survives on approximately US$ 180 per month.

Without access to basic medical care.

In a situation of extreme vulnerability.

81 years old. Blind. Widowed.

A decade of litigation. Billions in extraction.

Mina Boa Vista, in Catalão, Goiás, has operated on disputed land for over a decade — a process still without a definitive resolution between the Duarte Family and CMOC.

The extraction has never been interrupted.

~80,000 t niobium produced
between 2016–2026
~US$ 3.2 bn revenue generated
in the same period (est.)
6 deaths elderly co-owners
who died during the process
US$ 180/mo Glória Duarte's income
co-owner of the land
LITIGATION
10+ years of silence!

*open channel for CMOC to correct figures, if proven.

THE GLOBAL NIOBIUM SUPPLY CHAIN

The niobium extracted from Mina Boa Vista does not stay in Catalão. It crosses borders. It enters global supply chains. It reaches strategic sectors: defense, infrastructure, steel, mobility, energy and critical technologies.

The point is not a Brazilian land dispute.

The point is the legal, informational and ethical integrity of a globally significant mineral supply chain — the niobium chain — and the impossibility of actors in this chain claiming ignorance.

Global niobium chain →
This dossier was built for:
Who you are What you find here
Investor / Shareholder / Risk analyst Unprovisioned liability of up to US$ 3.2 bn — absent from CMOC reports (to be confirmed by investigators)
Auditor / ESG Agency / NGOs Violations of IAS 37, ISA 540, HKEX 13.09 — with verifiable primary source (to be confirmed by investigators)
Industrial niobium buyer LkSG/CSDDD exposure — supply chain due diligence (to be confirmed by investigators)
Regulator / Government Violation analysis by jurisdiction: HKEX, PCAOB, UN, EU (to be confirmed by investigators)
Citizen / Investigator 6 concrete actions — from sharing to formal regulatory reporting
THE BLIND SPOT
Blood Niobium operates exactly at the blind spot.

Every ton of niobium shipped carries with it:

  • A potential legal risk — unprovisioned, undisclosed
  • A possible regulatory omission — documented, verifiable
  • A history of human rights neglect that remained invisible for more than a decade

It does not merely narrate a case. It organizes evidence, translates risks and structures a documentary accountability protocol for actors who, until now, have benefited from the distance between the origin of the conflict and the international centers of decision.

GLOBAL ACTION
Why does this platform exist?

If the right information does not reach the centers of power — the CMOC board, the agencies that assign ESG ratings, the auditors who sign clean opinions, the regulators who oversee the market, the buyers who finance the extraction — silence continues to function as a shield.

Not enough to denounce.
It is necessary to translate.
Translate into the language of the markets.
Translate into the language of audits.
Translate into the language of certifications.
Translate into the language of the international press.
Translate into the language of regulators.
Translate into the language of every center of decision
that can, in fact, investigate and respond.
For this we offer 6 options for action. Choose how to act:
  1. Send a strategic suggestion (ideas, press contacts or support)
  2. Sign the support manifesto (registration as a moral witness)
  3. Send an email to break CMOC's silence (pre-written message to the board/investors/auditors)
  4. File the letter to Chairman Liu Jianfeng (download the open letter)
  5. Spread the visceral question on social media: “What if it were your mother?” (如果是你的毁伊呢?)
  6. Check your exposure level to risk (for stakeholders with a relationship to CMOC)

WHAT IF IT WERE YOUR MOTHER?

如果是你的毁伊呢?

The Face of Abandonment

WHILE GLÓRIA WAITS: US$ 3.2 BILLION EXTRACTED
Glória Duarte
Glória Duarte
BIOMETRIC FILE ID: GLD-81-CAT
Name: Glória Duarte
Age: 81 Years Old (Fragile health)
Status: Widow (63 years of marriage)
Aggravating: Blind (Progressive loss)
Income: US$ 180/month Insufficient for antibiotics
Location: Boa Vista Mine (disputed lands) — Catalão, GO
Status: MAXIMUM VULNERABILITY ⚠

CMOC's lawyers claim in Brazilian courts that elderly Glória Duarte's condition is one of "extreme comfort".

The Bucket of Shame

Symbol of Human Indignity — The Final Humiliation
最后的侮辱 (Zuìhòu de wŭrǔ) — The Final Humiliation
Jesus Duarte
Jesus Duarte 1935 — 2025
BIOMETRIC FILE ID: JSD-90-OBT
Name: Jesus Duarte
Age: 90 Years Old (Died in May 2025)
Status: Married (63 years — Family patriarch)
Cause/Death: Urinary complications. Unable to afford treatment. Used a urinary catheter connected to an improvised construction bucket.

A Chinese company internationally certified for ‘health care’ operates on judicially disputed lands, while the elderly co-owner of the mine dies without access to basic medical care.

Moral Context

In China, filial piety (Xiào - 孝) is the pillar of all morality. Neglect of one’s parents is the greatest dishonor.

GLÓRIA DUARTE MAY BE THE NEXT ELDERLY WOMAN TO DIE IN MISERY

The Morgue Curve

Read the text below the image to understand it.
CLASSIFIED LEVEL 5 RESTRICTED
The Mortuary Curve - Site of the 6 deaths
BLOOD-NB-2026 · FAILURE PROTOCOL · CRITICAL LEVEL
IRREVERSIBLE REMEDIATION FAILURE
DOCUMENTED

Six crosses.

They are there to show where profit was extracted — and dignity, buried.

Normative Obligation

The UN Guiding Principles on Business and Human Rights (UNGPs) classify as REMEDIATION FAILURE the moment when a company with a normative obligation to identify vulnerable groups, map impacts and remediate allows that window to close irreversibly with the death of the victim themselves.

The certifications held by CMOC — ISO 14001, ISO 9001, UN Global Compact — impose exactly that obligation.

The question these standards raise is direct: who had the obligation to act and did not act?

⚠ WARNING

The six elderly people did not die in the mine or because of mining. They died abandoned — 10 years in misery, while CMOC extracted US$ 3.2 billion in niobium from the disputed lands. Without any compensation. Without the extreme vulnerability of these people being even acknowledged.

When the remediation failure is irreversible, no subsequent ESG certification erases it.

Glória Duarte may be the next IRREVERSIBLE REMEDIATION FAILURE.

WHAT IF IT WERE YOUR MOTHER?

如果是你的母亲呢?

10 Years of Institutional Contempt

(2016–2026) Protocol: Exhaustion Tactic
WHAT IS THE EXHAUSTION TACTIC?

A deliberate strategy in which the wealthier party drags out legal proceedings, knowing that time favors those who can afford to wait. The calculation is clear: the longer the litigation, the lower the probability that elderly co-owners will survive to receive any compensation.

Jesus Duarte
THE HUMILIATION Jesus, 90 years old, in the final months of his life. Unable to afford medical treatment.
Glória Duarte
THE NEGLECT Glória, 81 years old, blind, widowed. Surviving on US$ 180/month. In poverty, without antibiotics.
The Question Every Investigator Must Ask

Is CMOC waiting for the natural death of elderly co-owners to avoid compensation — UNTIL ALL THE NIOBIUM IS EXTRACTED from the Boa Vista Mine in Brazil?

Is that what the facts authorize us to conclude?

Note:

CMOC DENIES any deliberate intent to exhaust the claimants. Yet CMOC has remained silent and disregarded the extreme vulnerability of elderly co-owners for more than 10 years.

Evidence of Institutional Abandonment

机构遗弃证据

The niobium extracted from the Boa Vista Mine does not stay in Catalão. It crosses borders and enters global supply chains in defense, steel, energy, and critical technologies.

This is not merely a Brazilian land dispute — it concerns the informational, legal, and ethical integrity of a globally strategic mineral supply chain: niobium.

Every ton shipped carries an unprovisioned legal liability, a potential regulatory omission, and a decade-long story of disregard for the human rights of elderly co-owners that has remained invisible.

Technical material documenting CMOC's conduct toward the co-owners of the Boa Vista Mine lands — Catalão, Goiás, Brazil.

Evidence 01 Origin: Boa Vista Mine
Period: 2016–2026
Revenue Comparison
  • Niobium: strategic mineral for military turbines, hypersonic missiles, and superconductors
  • Brazil holds 98% of global niobium reserves
  • CMOC has extracted for 10 years from land under active judicial dispute
  • Accumulated output: ~80,000 tonnes | Estimated revenue: ~US$ 3.2 billion
  • Glória Duarte, co-owner of the land, survives on ~US$ 180/month
Affected profiles: U.S. Government · Supply Chain Clients →
Evidence 02 Strategy: 拖延战术
Victims: 6
Death Certificates
拖延战术 — Delay Tactic
  • While CMOC exhausts Brazil's niobium reserves at the Boa Vista Mine, 6 elderly co-owners have died in poverty
  • The Goiás Court of Justice reversed the burden of proof in January 2026: CMOC must prove it does NOT operate on the family's land
  • Investigators must determine: Is the company deliberately stalling?
  • CMOC stays silent on Glória Duarte's extreme vulnerability while continuing to extract — record output of 10,024 tonnes in 2024
CONFIRMED: 6 DEATHS DURING PROCEEDINGS Action available: Guide for NGOs and Press →
Evidence 03 Code: 拖死 (Exhaust to Death)
Contradiction: Filial Piety
ESG CMOC
The ESG Paradox:
  • Jesus Duarte, 90, died urinating into a makeshift construction bucket
  • Glória Duarte, 81, blind — unable to afford antibiotics
  • CMOC holds: Wind China Top 100 ESG AAA (2025) and MSCI ESG Rating AA
  • In China, 孝 — filial piety — is the supreme moral pillar, in direct contradiction with the documented conduct
Affected profiles: ESG Certifiers · Chinese Government →
Evidence 04 Auditor: Deloitte
Failure: Material Misstatement
Provisions
Hidden Liability:
  • CMOC has operated for 10 years on disputed land without provisioning any contingent liability
  • Potential liability: up to US$ 3.2 billion (Art. 1,216 Brazilian Civil Code: 100% of proceeds in bad-faith possession)
  • IAS 37: failure to recognise provision for material contingency — Potential Material Misstatement
  • IAS 36: failure to perform impairment test on operational assets
  • HKEX 13.09: non-disclosure of material inside information
  • Responsible auditor: Deloitte
Action available: Guide for Auditors and Investors →

Section 07

VIOLATIONS GUIDE — ACCOUNTING VIOLATIONS

GLÓRIA DUARTE CANNOT INVESTIGATE THE VIOLATIONS. But You Can — And That Is Why This Guide Exists. For Regulators, Auditors, Certifiers, Clients, Investors, NGOs, Governments, Investigators and anyone with access to the information she does not have.
INTRODUCTORY NOTE

The Violations Guide was prepared based on public documents, financial statements disclosed by CMOC Group Limited itself (HKEX: 3993), court records and applicable international standards. It does not intend to replace specialized legal analysis or specialized investigations by profile of interested parties.

Its purpose is to organize information so that auditors, regulators, certifiers, clients, investigative journalists, investors and human rights organizations know which questions to ask, where to look for answers and which standards may have been breached.

Blood Niobium also exists to interrupt the institutional comfort zone that allows reports, ratings, investments, audits and industrial niobium purchases to keep circulating as if Glória Duarte’s situation of extreme vulnerability did not exist.

All independent factual verification is encouraged.

ACCOUNTING AND CAPITAL MARKETS VIOLATIONS

Financial statements of listed companies are regulated documents. When relevant litigation is ignored or inadequately provisioned, investors operate with distorted information. That is why the standards below exist.

VIOLATION 1 — IAS 37 · PROVISIONS AND CONTINGENT LIABILITIES AUDITORS · ANALYSTS · REGULATORS · INVESTORS
10+ years ignored!
IAS 37
What the standard requires
IAS 37 determines that a provision must be recognized when all the criteria below are present:
Criterion Question to ask Verifiable situation
Present obligation Is there active litigation with a legal obligation? Active land dispute for 10+ years
Past event Was extraction carried out in a disputed area? Continuous production since 2016 in area under dispute
Probability >50% Is there a judicial decision that increased the risk of loss? Reversal of burden of proof — TJ-GO, Jan/2026
Reliable estimate Is it possible to estimate the value? Revenue reported by CMOC: US$ 3.2B (2016–2024)
What CMOC’s public statements show
Provision recognized for this case: R$ 0.00 Specific disclosure in explanatory notes: ✘ Not identified Note on Duarte / Boa Vista Mine litigation: ✘ Not found Source: CMOC Financial Statements 2016–2025 (hkexnews.hk — code 3993)
Amount at risk — figures subject to independent confirmation
Scenario Calculation Basis Estimated Value
Minimum 5% of cumulative revenue US$ 66 million
Moderate 20% of cumulative revenue US$ 640 million
Maximum Art. 1,216 CCB — bad-faith possessor returns 100% of proceeds US$ 3.2 billion
QUESTIONS INVESTIGATORS SHOULD ASK CMOC: — Why did a 10+ year dispute generate no provision or robust disclosure? — On what basis did auditors classify the risk as “remote”? — Was the reversal of burden of proof (Jan/2026) considered in the risk reassessment? — What are the exact revenue figures from Boa Vista Mine, segregated?
🔴 STATUS: POTENTIAL MATERIAL MISSTATEMENT — to be confirmed by investigators

VIOLATION 2 — HKEX LISTING RULE 13.09 · MARKET DISCLOSURE HKEX · SFC · JOURNALISTS · INVESTORS
Inside info?
HKEX
What the standard requires
Rule 13.09(1) of the HKEX Main Board Listing Rules requires immediate disclosure of any information that, if made public, would materially affect the share price.
What was not adequately disclosed
Information Present in CMOC disclosures?
Active land dispute for 10+ years ✘ Not adequately identified
Contingent liability of up to US$ 3.2 billion ✘ Not mentioned
Risk of gross revenue restitution (Art. 1,216 CCB) ✘ Not mentioned
Reversal of burden of proof — TJ-GO (Jan/2026) ✘ Not mentioned
6 deaths of heirs during litigation ✘ Not mentioned
How to verify
Access hkexnews.hk, search for code 3993. Check for any mention of the Duarte dispute, the Boa Vista Mine in the context of a land dispute, or the contingent liability in explanatory notes of annual reports 2016–2025.
QUESTIONS INVESTIGATORS SHOULD ASK CMOC: — Did CMOC assess whether the Duarte dispute constitutes inside information as defined by the SFC? — Was there documented internal communication about the materiality of the dispute? — Was there insider trading in periods close to relevant judicial decisions?
Relevant regulatory precedents
The Hanergy (2015) and China Metal Recycling (2013) cases document severe SFC consequences for omission of material litigation and undisclosed contingent liabilities.
🔴 STATUS: POTENTIAL VIOLATION OF MANDATORY DISCLOSURE — to be confirmed by investigators

VIOLATION 3 — IAS 36 · ASSET IMPAIRMENT AUDITORS · CREDIT ANALYSTS · RATING AGENCIES
Overvalued assets?
IAS 36
What the standard requires
IAS 36 requires an impairment test when indicators are present, including litigation affecting rights of use or ownership, and adverse changes in the legal environment.
Assets at risk
Asset Nature Impairment Indicator
Goodwill (Niobras/Anglo American acquisition, 2016) Intangible allocated to CMOC Brasil CGU Litigation affects the legality of operations
Boa Vista Mine fixed assets Infrastructure and equipment Risk of forced shutdown
Mining rights Concessions Judicial challenge to ownership title
Indicators present and verifiable
✓ Active litigation affecting the legality of operations ✓ Risk of forced shutdown in case of unfavorable ruling ✓ Growing reputational damage with potential ESG downgrade ✓ Regulatory risk in multiple jurisdictions (EU, Germany, USA)
What was not identified in public statements
✘ Specific impairment test considering the Duarte dispute ✘ Disclosure of test assumptions including the legal risk ✘ Sensitivity analysis for adverse scenarios
Impairment scenarios for investigation
Scenario Trigger Event Potential Impairment
Moderate Partial unfavorable ruling 20–40% of goodwill
Severe Final unfavorable ruling 60–80% of goodwill
Catastrophic Operational shutdown 100% goodwill + fixed assets
🟠 STATUS: RISK OF ASSET OVERSTATEMENT — to be confirmed by investigators

Section 08

VIOLATIONS GUIDE — HUMAN RIGHTS VIOLATIONS

GLÓRIA DUARTE CANNOT INVESTIGATE THE VIOLATIONS. But You Can — And That Is Why This Guide Exists. For Regulators, Certifiers, NGOs, ESG Investors, Supply Chain Managers, Journalists and anyone with access to the information she does not have.
HUMAN RIGHTS AND ESG VIOLATIONS

Violations 4, 5 and 6 — LkSG/CSDDD, OECD/UNGPs and ESG inconsistency. Continuous extraction on disputed land, 10 years without any humanitarian remedy, directly contradicts the legal and voluntary obligations CMOC Group assumes in its reports and certifications.

VIOLATION 4 — LkSG (GERMANY) AND CSDDD (EU) · MANDATORY DUE DILIGENCE EU CLIENTS · BAFA · ESMA · NGOs · SUPPLY CHAINS
Due diligence ignored!
LkSG
What the standards require
LkSG — German Supply Chain Act (in effect since January 1, 2023): Companies operating in Germany or supplying the German market must: Identify human rights risks in the supply chain (§5) · Implement prevention measures (§6) · Remediate identified violations (§7) · Publicly report on measures taken (§10)
CSDDD — EU Corporate Sustainability Due Diligence Directive (2024, phased implementation through 2027–2028): Art. 7: Identify actual and potential human rights impacts · Art. 8: Prevent and mitigate through action plans · Art. 9: Remediate and establish accessible grievance mechanisms
The Duarte family’s documented situation — confrontation with legal requirements
Legal Requirement Verifiable Situation CMOC Action
Identify human rights risks 6 deaths, 81-year-old blind widow in extreme poverty ✘ Not identified in public reports
Mitigate adverse impacts Glória Duarte: USD 180/month, no access to medicine ✘ No mitigation measures documented
Remediate violations Zero compensation in 10 years of litigation ✘ Zero remediation
Grievance mechanism Multiple contact attempts with no response ✘ Ineffective or nonexistent
Publicly report CMOC ESG Report 2024 ✘ Case not mentioned
Identified vulnerable groups
Glória Duarte: elderly person (81 years old) — legally protected category Glória Duarte: person with disability (blind) — legally protected category Glória Duarte: widow in extreme poverty — socially vulnerable Deceased heirs (6 persons): all elderly · all in vulnerable situations · all died during litigation
QUESTIONS INVESTIGATORS SHOULD ASK CMOC: — Did CMOC conduct human rights due diligence on the Duarte family situation, as required by LkSG §5? — Does CMOC’s LkSG report document any prevention or remediation measures specific to the Duarte case? — How do CMOC’s European clients verify that purchased minerals comply with CSDDD requirements?
Prescribed penalties — for reference by regulators
Standard Penalty Supervisory Body
LkSG §24 Up to 2% of global annual turnover BAFA (Federal Office for Economic Affairs and Export Control, Germany)
CSDDD Art. 22 Civil liability + administrative fines Competent authorities in EU member states
Both Exclusion from European public contracts Procuring entities
🔴 STATUS: POTENTIAL VIOLATION OF MANDATORY DUE DILIGENCE OBLIGATIONS — to be confirmed by investigators

VIOLATION 5 — OECD GUIDELINES AND UNGPs · INTERNATIONAL HUMAN RIGHTS OECD NCP · UN PROCEDURES · NGOs · IACHR
Pattern worth investigating
OECD
What the frameworks require
OECD Guidelines for Multinational Enterprises (2023 revision): Respect internationally recognized human rights · Avoid causing or contributing to adverse impacts · Seek to prevent or mitigate impacts related to operations
UN Guiding Principles on Business and Human Rights — Pillar II (Responsibility to Respect): Principle 13: Commitment to respect rights, avoid adverse impacts and remediate when they occur · Principle 15: Human rights due diligence — identify, prevent, mitigate and communicate · Principle 22: Grievance mechanisms — operational, accessible and effective
Rights potentially violated — based on publicly documented facts
Right International Instrument Verifiable Situation
Right to property UDHR Art. 17 10 years of extraction on disputed land without compensation
Right to health ICESCR Art. 12 No documented access to essential medicines
Right to an adequate standard of living UDHR Art. 25 Income of USD 180/month, extreme poverty
Right to effective remedy UDHR Art. 8 Grievance mechanism ineffective or nonexistent

UDHR = Universal Declaration of Human Rights · ICESCR = International Covenant on Economic, Social and Cultural Rights

Pattern to be investigated — UNGPs Principles 13, 15 and 22
Continuous extraction on disputed land (2016–2025) → Systematic prolongation of litigation (10 years, successive appeals) → Complete absence of humanitarian negotiation (zero documented proposals) → Severe impact on vulnerable persons (6 deaths, 1 widow without support) = PATTERN TO BE INVESTIGATED
QUESTIONS INVESTIGATORS SHOULD ASK CMOC: — Has CMOC submitted any remediation plan to the OECD National Contact Points in Brazil, China, or Hong Kong? — What grievance mechanism was made available to the Duarte family, and why has it produced no result in 10 years? — Does the human rights due diligence in CMOC’s 2024 ESG report account for the Duarte litigation?
Available accountability mechanisms
Mechanism How to Use Expected Effect
Brazil OECD NCP Submit formal complaint Mediation + public statement
China OECD NCP Submit formal complaint Pressure on parent company
Hong Kong OECD NCP Submit formal complaint Pressure on HKEX-listed company
UN Special Rapporteurs Individual communication International visibility
Inter-American Court of Human Rights After exhausting domestic remedies Case law on state omission
🔴 STATUS: NON-COMPLIANCE WITH INTERNATIONAL HUMAN RIGHTS STANDARDS — to be confirmed by investigators

VIOLATION 6 — INCONSISTENCY BETWEEN ESG CERTIFICATIONS AND DOCUMENTED REALITY MSCI ESG · RMI · NOSA · SUSTAINALYTICS · FTSE RUSSELL · ESG FUNDS
AA rating with 6 deaths?
ESG
The verifiable paradox
✓ CMOC Group simultaneously holds: ✓ MSCI ESG Rating: AA (industry leader in mining)
✓ RMI Certification (Responsible Minerals Assured — including Boa Vista Mine)
✓ NOSA HSE 5 Stars (Health, Safety and Environment excellence certification)
✓ S&P Global Sustainability Yearbook · FTSE4Good Index
✘ Meanwhile, verifiable with public documentation: ✘ Operating on disputed land for 10+ years
✘ 6 elderly heirs died during litigation
✘ 81-year-old blind widow living on USD 180/month
✘ Multiple humanitarian contact attempts with no response
CENTRAL QUESTION FOR CERTIFICATION BODIES: — Either the certifications are wrong or the facts are wrong. Investigators have documentary evidence of the facts. Do certifying bodies have evidence of the certifications?
Analysis of MSCI ESG Research — by Pillar
ESG Pillar Current Rating Documented Reality
Environmental (E) A No significant environmental disputes identified
Social (S) AA 6 deaths, widow in extreme poverty, zero compensation
Governance (G) A Material liability omitted, inadequate disclosure
Analysis of Responsible Minerals Initiative (RMI) — RMAP Criteria Verification
RMAP Criterion Requirement Verifiable Situation In Compliance?
Company Management Systems Human rights due diligence 10-year litigation, zero remediation
Risk Identification Identify operational risks Risk not identified in public ESG reports
Risk Management Mitigate identified risks Zero mitigation (6 deaths, extreme poverty)
Independent Audit Third-party audit Did the audit account for this litigation? ⚠ Questionable
Grievance Mechanism Effective grievance mechanism Multiple contacts with no response
FOR NOSA — QUESTION OF SCOPE: — During the same period that CMOC received its “Excellence in Health” certification, the alleged landowner Jesús Duarte (aged 90) reportedly died unable to afford medical expenses, using a catheter connected to a construction bucket. Does the HSE 5 Stars certification account only for the health of company employees, or also for the health of communities affected by operations?
⚠️ STATUS: CENTRAL ESG PARADOX — Certifications require independent review — to be confirmed by investigators

RISK GUIDE BY PROFILE

GLÓRIA DUARTE CANNOT WARN THE WORLD. But You Can — And the World Needs to Know.
PROFILE IDENTIFICATION Who can be reached by violations in the mineral extraction at Mina Boa Vista — Catalão, Goiás, Brazil
⚠ METHODOLOGICAL NOTE — READ BEFORE CONTINUING

All risks identified below are potential — based on public documents, applicable international standards, and independently verifiable facts. No classification constitutes a definitive legal, regulatory, or audit conclusion.

The purpose of this guide is to organize verifiable information so that each group can find its entry point for investigation — which questions to ask, which documents to access, and which standards may have been breached.

This dossier was built so that you can act within your own sphere — whether as a risk analyst in London, a journalist in New York, an auditor in Hong Kong, an investor in Shanghai, or a Department of Defense official in Washington.

The Risk Guide by Profile offers: individualized analysis of the legal, financial, and reputational exposure of 9 categories of stakeholders who operate with CMOC or its products. 9 profiles. 9 exposures. One unprovisioned liability of up to US$ 3.2 billion.

CMOC Group Limited denies any irregularity in the ownership of the area. All independent factual verification is encouraged. All conclusions must be confirmed by investigators.

EXPOSURE TO RISK
WHO IS EXPOSED TO THE US$ 3.2 BILLION GAP?

9 entities face legal, reputational, or financial exposure due to accounting, humanitarian, and regulatory violations by CMOC.

IDENTIFY YOUR LEVEL OF RISK EXPOSURE NOW

CONTROLLING SHAREHOLDERS

Central Risk

Fiduciary duty — destruction of value

VIEW PROFILE IN RISK GUIDE →

INSTITUTIONAL INVESTORS

Central Risk

Material misstatement — ESG downgrade

VIEW PROFILE IN RISK GUIDE →

INDEPENDENT AUDITORS

Central Risk

Audit failure — professional liability

VIEW PROFILE IN RISK GUIDE →

MARKET REGULATORS

Central Risk

Disclosure violation — market integrity

VIEW PROFILE IN RISK GUIDE →

ESG CERTIFICATION BODIES

Central Risk

Systemic greenwashing — sector credibility

VIEW PROFILE IN RISK GUIDE →

SUPPLY CHAIN CUSTOMERS

Central Risk

LkSG/CSDDD — Blood Niobium in the final product

VIEW PROFILE IN RISK GUIDE →

GOVERNMENT OF THE PEOPLE’S REPUBLIC OF CHINA

Central Risk

National reputation — values betrayed

VIEW PROFILE IN RISK GUIDE →

UNITED STATES GOVERNMENT

Central Risk

National security — contaminated critical minerals

VIEW PROFILE IN RISK GUIDE →

PRESS, NGOS & CIVIL SOCIETY

Central Risk

Public interest — documented human rights

VIEW PROFILE IN RISK GUIDE →
Profile 01 of 09
CONTROLLING SHAREHOLDERS

(Cathay Fortune Corporation · Yu Yong · Zhang Lihua · other CMOC controlling shareholders HKEX: 3993)

Controlling shareholders who knew — or should have known — of a potential contingent liability of up to US$ 3.2 billion and took no action may face personal liability for breach of fiduciary duty and erosion of corporate control.— To be confirmed by investigators.

TWO QUESTIONS THAT DEFINE THE RISK: — If the controllers know: why are they allowing this to continue?
— If the controllers don’t know: what kind of governance allows management to conceal a litigation of this magnitude from those in control?

Both answers carry serious legal implications.

Estimated Financial Exposure:

ScenarioBasisPotential exposure
Minimum5% of cumulative revenueUS$ 66 million
Moderate20% of cumulative revenueUS$ 640 million
MaximumArt. 1,216 Brazilian Civil Code — bad-faith possessor returns 100% of proceedsUS$ 3.2 billion

Figures subject to confirmation by investigators.

Legal Risks to Investigate:

  • Hong Kong Companies Ordinance: action for breach of fiduciary duty
  • Brazilian Corporate Law (Law 6,404/76): violation of duty of diligence, Art. 153
  • HKEX/US Securities Laws: minority shareholder class actions for inadequate disclosure

Available Actions:

  • Instruct management to acknowledge the situation publicly and negotiate a humanitarian resolution → asset and reputational protection
  • Maintain silence → HKEX/SFC investigation, ESG downgrades, class actions, erosion of control
VIEW PROFILE IN RISK GUIDE →
Profile 02 of 09
INSTITUTIONAL INVESTORS

(BlackRock · Vanguard Group · State Street · Fidelity · other funds with HKEX: 3993 exposure)

Funds holding CMOC exposure may be carrying a hidden potential liability of up to US$ 3.2 billion in their portfolios without knowing it — because the financial statements do not adequately disclose the risk.— To be confirmed by investigators.

MATERIAL MISSTATEMENT NOTICE — THREE POTENTIAL VIOLATIONS:
StandardPotential violationPortfolio impact
IAS 37Contingent liability of up to US$ 3.2B not provisionedRisk of retroactive restatement
HKEX Rule 13.09Inside information not disclosed to the marketIncorrect share pricing
IAS 36Assets with impairment indicators not testedGoodwill overstatement of up to 80%
Downgrade and Index Exclusion Risk If confirmed, MSCI ESG downgrade from AA to BBB− affects:
— MSCI ESG Leaders Indexes: ~US$ 1.2 trillion AUM
— FTSE4Good Index Series: ~US$ 800 billion AUM
— S&P ESG Index Family: ~US$ 500 billion AUM

Exclusion triggers forced selling by passive funds → selling pressure → price decline.
QUESTIONS FIDUCIARY MANAGERS MUST ASK CMOC: — Why has a 10-year litigation generated no provision or adequate disclosure?
— Why did the reversal of the burden of proof (Jan/2026) not raise the risk classification?
— Why do 6 heirs’ deaths during litigation not constitute a severe ESG red flag?
VIEW PROFILE IN RISK GUIDE →
Profile 03 of 09
INDEPENDENT AUDITORS

(Deloitte Touche Tohmatsu — CMOC Group Limited auditor, 2016–2024)

Deloitte issued clean opinions on statements that potentially omit a liability of US$ 66 million to US$ 3.2 billion — and in doing so may have violated up to four international audit standards simultaneously.— To be confirmed by investigators.

THE QUESTION THAT DEFINES THE RISK: Did Deloitte obtain sufficient evidence about an active land dispute of 10+ years with a potential liability of this magnitude before issuing clean opinions?

— If YES: why is there no IAS 37 provision or robust disclosure?
— If NO: how was ISA 501 (Audit Evidence — Litigation and Claims) complied with?
StandardVerifiable situationPotential status
IAS 37R$ 0 provisioned for litigation active 10+ years with burden of proof reversal🔴 Material Misstatement
IAS 36Goodwill from Niobras/Anglo American acquisition with no impairment test considering the litigation🟠 Potential overstatement
ISA 501External counsel letters and judicial filing review — obtained?⚠ Questionable
ISA 260/701Litigation of this magnitude not listed as KAM in the opinion⚠ Potential omission

Regulatory Exposure to Investigate:

  • AFRC (Hong Kong): formal complaint, investigation, fines, registration suspension
  • PCAOB (USA): deficiency tip, extraordinary inspection
  • CVM (Brazil): notification and investigation of subsidiary

If individual auditors identified this risk and faced pressure to ignore it, protection channels exist: AFRC Whistleblower Hotline and PCAOB Tips & Referrals.

VIEW PROFILE IN RISK GUIDE →
Profile 04 of 09
MARKET REGULATORS

(HKEX Listing Division · SFC · CSRC · CVM · PCAOB)

The inadequate non-disclosure of a potential contingent liability of up to US$ 3.2 billion — which meets all criteria for inside information under Listing Rule 13.09 — represents a possible violation of disclosure obligations that HKEX and the SFC have a legal mandate to investigate and penalize.— To be confirmed by investigators.

InformationMaterial?Non-public?Would affect price?Disclosed?
Active land dispute for 10+ yearsYesNon-publicYes✘ Inadequate
Contingent liability US$ 66M–3.2BYesNon-publicYes✘ Not disclosed
Reversal of burden of proof (Jan/2026)YesNon-publicYes✘ Not disclosed
6 heirs’ deaths during litigationMedium (ESG)Non-publicYes✘ Not disclosed
QUESTIONS FOR REGULATORY INVESTIGATION: — When did CMOC become aware of the litigation and assess its materiality?
— Why was there no immediate disclosure following the reversal of the burden of proof?
— Was there insider trading near the dates of relevant judicial decisions?
Relevant Regulatory Precedents Hanergy (2015) and China Metal Recycling (2013) document severe SFC consequences for omitting material litigation — including permanent suspension and delisting.

International cooperation available: CVM via IOSCO · SEC via ADRs · ESMA via EU bond issuance.
VIEW PROFILE IN RISK GUIDE →
Profile 05 of 09
ESG CERTIFICATION BODIES

(MSCI ESG Research · RMI · NOSA · Sustainalytics · FTSE Russell · S&P Global)

If certifications continue to ignore the documented reality, ESG bodies are actively validating a case that may be cited as proof that ESG ratings are instruments of greenwashing — not genuine risk management.— To be confirmed by investigators.

The Central Paradox — Publicly Verifiable:

✓ CMOC SIMULTANEOUSLY HOLDS:
  • ✓ MSCI ESG Rating: AA (Leader — top 19%)
  • ✓ WIND CHINA TOP 100 ESG: AAA (2025)
  • ✓ RMI Certified (includes Mina Boa Vista)
  • ✓ NOSA HSE 5 Stars (Health & Safety)
  • ✓ UN Global Compact (HR since 2022)
  • ✓ FTSE4GOOD (1st inclusion 2024)
  • ✓ UN SDG Seal (Dec/2025)
✗ AND THE DOCUMENTED FACTS SHOW:
  • ✗ 6 heirs’ deaths during litigation
  • ✗ Blind widow, 81, living on US$ 180/month
  • ✗ Zero compensation in 10 years of litigation
  • ✗ Jesus Duarte died holding a construction bucket
  • ✗ Numerous humanitarian contacts ignored
  • ✗ Zero litigation disclosure in financial reports
  • ✗ Zero accounting provision recorded
THE CENTRAL QUESTION FOR ALL BODIES: Either the certifications are incorrect, or the facts are incorrect.
This guide has evidence of the facts. The bodies have evidence of the certifications.
What explains the coexistence of both? — To be answered by investigators.

Pillar Analysis — for MSCI ESG Research:

PillarCurrent ratingDocumented realityRating justified?
Environmental (E)ANo major environmental controversies identifiedMay maintain
Social (S)AA6 deaths · widow in extreme poverty · zero compensation❔ Urgent review required
Governance (G)AOmission of material liability · inadequate HKEX disclosure❔ Urgent review required
Applicable MSCI controversy categories:
Human Rights & Community Relations → 🔴 Category 4–5 (Red Flag — maximum severity)
Access to Basic Services → 🔴 Category 4
Business Ethics → 🟠 Category 3

A downgrade from AA to BB represents a drop from “Leader” to “Laggard” on the MSCI scale — with direct impact on ESG index funds with minimum rating thresholds.

For RMI — RMAP criteria:

CriterionRequirementVerifiable situationIn compliance?
Company Management SystemsHuman rights due diligence10-year litigation · zero remediation
Risk IdentificationIdentify risksRisk not mentioned in ESG reports
Risk ManagementMitigate risksZero mitigation · 6 deaths · extreme poverty
Independent AuditThird-party auditDid audit consider the litigation?⚠ Question
Grievance MechanismEffective mechanismNumerous attempts without response

The RMI certification is used by Boeing, Airbus, BMW, and Volkswagen. If maintained after the publication of this guide, these companies will have documented knowledge of the risk — activating their own due diligence obligations under LkSG and CSDDD.

For NOSA — Scope Question: Does the HSE 5 Stars certification cover only CMOC’s direct employees, or also communities affected by the operation?
— If only employees: insufficient scope — must be stated explicitly on the certificate
— If also communities: certification granted based on incomplete information

In either case: the certificate’s usefulness as a third-party due diligence tool is compromised.

Systemic Failures Identified — for ESG system reform:

FailureDescriptionConsequence
Self-Reporting BiasRatings based on company’s own dataCompanies build their own ratings
Narrow ScopeCertifications focus on employees, ignore communitiesExternal impacts remain invisible
Lack of Independent VerificationAffected parties rarely consultedInformation comes 100% from the company
Slow Controversy UpdatesControversies take months to reflect in ratingsInvestors operate with outdated data
VIEW PROFILE IN RISK GUIDE →
Profile 06 of 09
SUPPLY CHAIN CUSTOMERS

(ArcelorMittal · Nippon Steel · Boeing · Airbus · Tesla · Volkswagen · Toyota · GE Aerospace · Rolls-Royce · Siemens Energy)

Every customer that buys niobium from CMOC may be incorporating Blood Niobium into their final product — and from the moment they are formally alerted to the risk, they incur active legal obligations under Germany’s LkSG and the European CSDDD.— To be confirmed by investigators.

What “Blood Niobium” means for compliance purposes:
Niobium extracted from:
→ Land under active ownership dispute for 10+ years
→ An operation with 6 deaths of extremely vulnerable local community members during the litigation
→ A critical human situation with no documented remediation
→ No compensation or consent in 10 years

This niobium is in your final product. Not as an allegation — as a verifiable fact with public documentation.

Active Legal Obligations — LkSG (Germany):

(in force since 01/01/2023 — companies with 1,000+ employees in Germany)

LkSG ObligationRisk with CMOC after this alert
§5 — Identify risksIf you did not question CMOC: active risk
§6 — Preventive measuresIf you did not demand remediation: active risk
§7 — Remediate violationsIf you maintain the relationship post-alert: growing risk
§10 — Report publiclyBlood Niobium must appear in the annual report

LkSG §24 penalties: fines of up to €8 million or 2% of global revenue · exclusion from public tenders for up to 3 years · civil liability for damages.

Active Legal Obligations — CSDDD (European Union):

(adopted 2024 · phased implementation 2027–2028)

ArticleObligationRelevance for CMOC customers
Art. 7Identify actual and potential impactsBlood Niobium = documented impact
Art. 8Prevent and mitigate with an action planRequires response after this alert
Art. 9Remediate and maintain grievance mechanismRequires cooperation with affected parties
Art. 29Civil liabilityKnowledge condition met from this alert

CSDDD Art. 23 penalties: fines of up to 5% of global revenue · exclusion from EU public contracts · direct civil actions by victims against downstream companies.

ACTION PLAN — 72 HOURS: — 24h: Alert CPO, CSO, and General Counsel · convene crisis management meeting
— 48h: Send formal communication to CMOC demanding full disclosure, evidence of remediation, and certification that the niobium supplied does not originate from disputed land
— 72h: Decision based on the response — demand remediation plan or begin supplier diversification
VIEW PROFILE IN RISK GUIDE →
Profile 07 of 09
GOVERNMENT OF THE PEOPLE’S REPUBLIC OF CHINA

(SASAC · Henan Party Committee · MOFCOM · Chinese Embassy in Brazil)

CMOC’s documented conduct directly contradicts the Confucian values that the Party and Chinese government promote as the foundations of Chinese civilization — and the world is associating this contradiction not with the company, but with China.— To be confirmed by investigators.

The Problem in International Headlines
What circulates in the international press does not say “CMOC.” It says “Chinese company”:

“Chinese Mining Giant Faces Blood Niobium Allegations”
“6 deaths during dispute with Chinese mining company in Brazil”
“Chinese company leaves blind 81-year-old widow on US$ 180/month while extracting billions”

These headlines affect all Chinese companies operating in Brazil and around the world.

The Contradiction With National Values:

Taught valueCMOC’s verifiable conductInternational perception
寊 Filial piety81-year-old abandoned · US$ 180/monthChina does not respect its elders
仁 BenevolenceZero compensation in 10 years · 6 deathsChinese corporate impunity
御 IntegrityNumerous contacts without responseChinese companies are opaque

百善孝为先 — Of the hundred virtues, filial piety comes first.
CMOC, a company of Chinese origin, is dishonoring in Brazil the very value that China most proudly teaches the world.

Impact on the Belt and Road Initiative (BRI):

BRI pillarBlood Niobium impact
Trust of partner countries“If China does this in Brazil, it will do it here too”
Win-win cooperationChina gains billions · Brazil gets a poor widow
Cultural soft powerChinese values are mere rhetoric

Available Mechanisms:

  • SASAC: convene an international conduct audit of CMOC
  • Henan Party Committee: summon CMOC leadership to account for its conduct
  • MOFCOM: condition support to companies with responsible conduct abroad
  • Embassy in Brazil: facilitate dialogue between CMOC and the Duarte Family

Positive precedent: Sinopec/Angola (2012) — Chinese government intervention led to negotiation, compensation, and image preservation.

VIEW PROFILE IN RISK GUIDE →
Profile 08 of 09
UNITED STATES GOVERNMENT

(DoD · CFIUS · USGS · NSC · State Department · Bureau of Industry and Security)

Niobium from Mina Boa Vista enters the American critical minerals supply chain and may be contaminating defense, aerospace, and automotive applications with Blood Niobium of disputed origin, controlled by a Chinese company.— To be confirmed by investigators.

Executive Summary for Agency Review:

FactorDataClassification
Niobium statusCritical MineralExecutive Order 13817
CMOC share~15% of global marketStrategic dependency
US dependency100% imported — zero domestic productionCritical vulnerability
Primary sourceBrazil 92% — includes CMOCConcentration risk

Niobium Applications in the American Supply Chain:

SectorPrimary useSubstitutability
DefenseHigh-strength steel · armor · aircraft✘ None
AerospaceSuperalloys for jet engines⚠ Limited
AutomotiveHSLA steel for light vehiclesPartial
EnergyPipelines · nuclear reactors⚠ Limited
Three Risk Scenarios for Agency Analysis:

Scenario 1 — Reputational contamination:
“Your F-35 contains Blood Niobium” | “Your Tax Dollars Fund Blood Niobium from China”
Public backlash against defense contractors

Scenario 2 — European regulatory action with American impact:
EU bans CMOC niobium under CSDDD → American contractors with EU operations seek alternative sources in an emergency → supply chain disruption affecting defense programs

Scenario 3 — Chinese geopolitical leverage:
China via CMOC threatens to reduce supply in response to trade tensions → national security vulnerability exposed
GEOPOLITICAL CONTEXT: In 2023, the US Congress listed CMOC among Chinese companies with potential critical mineral implications. Blood Niobium adds a human rights dimension to the geopolitical risk that unites progressive and conservative lawmakers around the same demand: origin transparency.
Strategic questionRelevance
Does a company under Chinese state influence control a critical mineral for American armor?National security
Is the land dispute negligence or calculated indifference in a context of asymmetric dependency?Geopolitical intelligence
If US-China trade tensions escalate, how vulnerable is the niobium chain?Defense resilience
Is there a difference between buying Blood Niobium from CMOC and financing a company under Chinese geopolitical control?Industrial policy

Actions US Agencies May Consider:

  • Department of State — Bureau of Democracy, Human Rights, and Labor: Include the Duarte Family vs. CMOC case in the next Country Reports on Human Rights Practices — Brazil · Recommend contact with OECD NCPs · Assess whether CMOC’s conduct pattern warrants bilateral communication with Brasília
  • Department of Commerce — Bureau of Industry and Security: Add human rights audit to the critical minerals certification process · Review whether niobium suppliers in federal contracts are subject to minimum supply chain due diligence
  • Department of Defense — Defense Logistics Agency: Map the percentage of niobium in active contracts originating from CMOC/Mina Boa Vista · Assess the cost of diversification vs. reputational exposure in high-profile programs (F-35, M1 Abrams) · Include human rights risk as a qualification criterion for strategic mineral suppliers
  • National Security Council: Develop an interagency position on niobium as a dual-risk mineral — strategic and humanitarian · Consider Blood Niobium as a pilot case for structuring ethical sourcing policy for critical minerals

All aspects must be confirmed by investigators.

VIEW PROFILE IN RISK GUIDE →
Profile 09 of 09
PRESS, NGOs & CIVIL SOCIETY

(FT · Bloomberg · Reuters · NYT · Amnesty International · Human Rights Watch · Global Witness · FIAN Brasil · academic researchers · impact lawyers)

This is not a case that needs to be discovered — it already exists, documented, with public court records, verifiable death certificates, and an 81-year-old survivor who can be interviewed. The risk here is of not covering it.— To be assessed by each outlet and organization.

Why This Case Is Editorially Relevant:

ElementEditorial relevance
Global critical mineral — niobiumMarket of US$ 3.2B in cumulative revenue
Publicly listed multinationalHKEX — transparency required, compliance verifiable
10-year land disputeBrazilian judiciary with public documentation
6 documented deaths during proceedingsPublic death certificates
81-year-old survivor, blind, US$ 180/monthCentral character — alive and interviewable
Lawyers’ claim of “extreme comfort”Factual conflict documented in court filings
Potential violation of IAS 37, LkSG, UNGPsGlobal financial and regulatory dimension
POINT 1 — THE HUMAN STORY: Glória Duarte — 81 years old, blind, illiterate, widowed. She lives in Catalão, Goiás, a few kilometers from the mine that extracts billions in niobium from the land she claims. She survives on the equivalent of US$ 180 per month. She has no money for antibiotics.

The verifiable contrast:
~US$ 2.5 million/day extracted from the disputed land (to be confirmed by investigators)
US$ 180/month — Glória Duarte’s income

What CMOC’s lawyers said in a court filing: that Glória’s situation is “extremely comfortable”
What any reporter with access to the case file can verify: the real living conditions, the medical care history, and the documented financial reality of the family.
Independently Verifiable Sources:
📁 Public court record — Tribunal de Justiça de Goiás (e-SAJ)
📁 Death certificates of the 6 heirs — public records
📁 Court filings with “comfort” claim — public case document
📁 CMOC financial reports — hkexnews.hk, code 3993
📁 CMOC Brasil statements — Junta Comercial de Goiás
📁 Mining concessions — SIGMINE/ANM (anm.gov.br)
📁 CMOC ESG Report 2024 — cmocgroup.com, Investor Relations
POINT 2 — THE FINANCIAL INVESTIGATION: A company listed on the Hong Kong Stock Exchange reports US$ 3.2 billion in niobium revenue while maintaining a potential contingent liability of up to that same amount outside its financial statements.

Core verification questions:
— Does the Duarte Family vs. CMOC Brasil litigation appear in the notes as a contingent liability? With what classification (remote/possible/probable)?
— Is any provision recorded related to the case?
— Was the Niobras acquisition goodwill (2016) tested for impairment considering the litigation?
— What is the Key Audit Matter (KAM) in Deloitte’s opinion — does the Duarte litigation appear?
POINT 3 — HUMAN RIGHTS: The situation is not the result of a single event. It is the result of a 10-year pattern: continuous extraction on disputed land with no compensation, 6 deaths of elderly heirs with no action by CMOC in the face of extreme vulnerability, total absence of humanitarian negotiation, and public characterization of the situation as “comfortable” by the company’s legal representatives.
RightInstrumentVerifiable situation
Right to propertyUDHR Art. 17Extraction without compensation for 10 years on disputed land
Right to healthICESCR Art. 12No access to essential medicines
Right to adequate standard of livingUDHR Art. 25US$ 180/month in extreme poverty
Right to effective remedyUDHR Art. 8Ineffective grievance mechanism
Right to non-discriminationUDHR Art. 2 · CEDAWElderly, blind, illiterate woman — multiple vulnerabilities
POINT 4 — THE SYSTEMIC QUESTION: How can a company with an MSCI ESG Rating AA, RMI certification, and NOSA HSE 5 Stars simultaneously have 6 heirs’ deaths during litigation, an 81-year-old widow with no access to medicine, and zero compensation in 10 years — without any of these ratings recording even a single controversy?
ESG failureEvidence in the CMOC caseSystemic implication
Self-reporting biasAA rating based on data supplied by CMOCAny company can build its own rating
Narrow scope for employeesNOSA ignores community impactAffected communities have no visibility
Absence of external stakeholderGlória Duarte was never consulted by any certifying bodyMost affected parties are the most silenced
Slow updatesBlood Niobium controversy not reflected in ratingsInvestors buy shares with outdated ratings
NGO Action Guide — via OECD NCP:
Step 1 — Prepare formal complaint with documented facts
Step 2 — Submit to NCP Brazil (MDIC) and/or NCP China and NCP Hong Kong
Step 3 — NCP conducts initial admissibility assessment
Step 4 — If admitted: mediation or public statement
Step 5 — Final statement published — with or without agreement

Via UN Special Rapporteur: submit individual communication to the Special Rapporteur on Business and Human Rights. The Rapporteur may send a formal communication to CMOC and the Brazilian government.
VIEW PROFILE IN RISK GUIDE →
THE RESPONSE

THE FACTUAL SITUATION INDICATES: MAINTAINING SILENCE DOES NOT REDUCE THE RISK — IT INCREASES IT.

TODAY
Verifiable inadequate disclosure
30 DAYS
Organized investigation action · investor letters · engagement
90 DAYS
Restatement · Formal downgrades · HKEX · SFC · BAFA · OECD NCPs
180 DAYS
Irreversible exclusion from global ESG indexes
12 MONTHS
No honorable exit possible

Every week without a response: more stakeholders alerted · more accumulated regulatory action · more irreversible reputational damage · fewer honorable exit options available.

Document Access — All Profiles (Upon credentialing)

Document typeAvailability
Complete court recordsImmediate
Death certificates — 6 heirsImmediate
Court filings with “extreme comfort” claimImmediate
CMOC financial reports with omission analysisImmediate
Technical analysis IAS 37 · IAS 36 · ISA 501Immediate
Glória Duarte’s health documentationImmediate
Documented photographs of living conditionsImmediate
Record of contact attempts with CMOCImmediate

Contact us at the official email: info@bloodniobium.org
Please identify your profile when contacting: investor · auditor · regulator · journalist · NGO · researcher · lawyer · government.

Glória Duarte cannot warn the world.

She has no way to call BlackRock.

She has no way to make Deloitte read the dossier.

She has no way to contact the BAFA in Berlin.

She has no access to the CMOC chairman in Hong Kong.

She has no way to send reports to the PCAOB in Washington.

She has no way to request a rating downgrade from MSCI.

She has no way to file a complaint with HKEX.

She has no way to appear in Davos, Hong Kong, Brussels, or Washington.

But you do.

The risks exist. For investors. For auditors. For regulators. For customers. For certifiers. For governments. For the press. For anyone with a conscience and access to information.

You have read the guides. You now know the violations and the risks. You know what is at stake.

And you have what Glória Duarte does not:

Access to regulators and certifiers.
Access to the market.
Access to the press.
Access to international justice.

You have the power to act.

Glória Duarte is running out of time. She is in Catalão, Goiás. 81 years old. Blind. Living on US$ 180 per month. While the land she claims generates approximately US$ 2.5 million per day — a figure to be confirmed by investigators.

“Injustice anywhere is a threat to justice everywhere.”
— Martin Luther King Jr., Letter from Birmingham Jail, 1963

THE CONSULTATION THAT CHANGED EVERYTHING

Gloria's Letter to Liu (CMOC CEO)

It was here necessary to transform the invisible suffering of an elderly Brazilian woman into documentary language capable of crossing political, financial, regulatory, and moral borders.

UNDERSTAND HOW THE PLATFORM AND GLOBAL ACTION CAMPAIGN WERE BORN:

The Question She Asked

G

Glória Duarte 81 years old

Co-owner · Boa Vista Mine, Catalão, GO · Monthly allowance: R$ 1,600

Glória Duarte

"When we started documenting CMOC's neglect, I myself asked: what would you do to make the most powerful man at CMOC, over in China, know what is happening to me here?"

The Answer That Changed Everything

Chinese Student

Based in São Paulo, Brazil

Chinese Student

"I would make the whole world ask him: WHAT IF IT WERE YOUR MOTHER? 如果是你的母亲呢?"

Because in my culture, you don't attack a man's wallet first; you question his honor. In China, honoring one's parents is the supreme moral pillar: 百善孝为先 — of the hundred virtues, respect for one's parents is the first of all.

Official Document

OPEN LETTER TO THE CHAIRMAN

Recipient: Chairman & CEO

Mr. Liu Jianfeng (刘建峰)

CMOC Group Limited • Hong Kong

Mr. Liu,

You do not know me. My name is Glória Duarte. I am 81 years old, a widow, and I can no longer see. I live in Catalão, Goiás, on land that is rightfully mine — the same land from which your company extracts billions of reais every year.

My husband, Jesus, passed away last year at the age of 90. In his final months, he urinated into a construction bucket because we could not afford a catheter. He died that way — without the slightest dignity. Meanwhile, your company's lawyers told the court that I live in "extreme comfort."

Mr. Liu, I survive on a pension of R$ 1,600 per month. I cannot afford antibiotics when I need them. Six elderly co-owners died over these ten years of legal proceedings — without seeing a single day of justice. Jesus was the last. I may be next.

I know that in your culture there is a teaching: 百善孝为先 — of the hundred virtues, respect for one's parents is the first of all. I am not invoking this as a legal argument. I am invoking it as an appeal from a mother to a son who was raised to know what honor means.

Do not come to me with lawyers' arguments, Mr. Liu. I have listened to lawyers for ten years. Come with respect. Does your company not uphold certifications that require it to consider stakeholders and observe the human rights of elderly people?

What I Ask

1. Recognition: That CMOC acknowledge my condition of extreme vulnerability.
2. Negotiation: A real dialogue — send someone with immediate decision-making power.
3. Dignity: That the niobium from my land no longer carry blood in its name.

Time is running out for me, Mr. Liu. Not for the lawsuit. Not for your company. For me.
And so I ask you, Mr. Liu:

WHAT IF IT WERE YOUR MOTHER?

如果是你的母亲呢?

With the dignity I still have,

Glória Duarte

Co-owner of the lands of Boa Vista Mine · Catalão, Goiás, Brazil · 81 years old

BLOOD NIOBIUM 2026
📧 SEND DIRECTLY TO CMOC BOARD →
How it works: Clicking opens your email client (Outlook, Gmail, Apple Mail) automatically with recipients 603993@cmoc.com · investor@cmoc.com · chenchao@cmoc.com, subject and full letter text already filled in. Review and click Send.
How it works: Clicking copies the full letter to your clipboard. Then choose a network — each button opens the platform in a new window with text ready to share.
✓ LETTER COPIED — PASTE ANYWHERE

What If She Were Your Mother?

While CMOC extracts billions in niobium from disputed land, Glória Duarte — 81 years old, blind, widowed, and co-owner of the area — remains reduced to a convenient absence. For more than 10 years, CMOC’s institutional neglect has transformed ongoing human suffering into a mere property dispute. Reports circulate. Audits proceed. Certifications preserve appearances. And amid all of this, one inevitable question: What if she were your mother?

In China, honoring one’s parents is the supreme moral pillar: 百善孝为先 — of the hundred virtues, respect for parents comes first.

PHOTO DOCUMENTARY • PROTOCOL: MOTHERS-BLOOD-2026

Mother
母亲 Mother
Filial Piety
孝道 Filial Piety
Dignity
尊严 Dignity
Family
家庭 Family
Maternal Love
慈爱 Maternal Love
Sacrifice
牺牲 Sacrifice
Memory
记忆 Memory
Justice
正义 Justice

“Every mother deserves dignity, regardless of where she was born.”

Get in Touch

Official Contact Channel We respond within 72h
Email
info@bloodniobium.org
General inquiries & press
WhatsApp
+55 (64) 99647-1405
Glória Duarte
REQUEST THE OFFICIAL DOCUMENTS
RELATED TO THIS CASE HERE
Send a Message
✓ Message received. Protocol: — We will be in touch shortly.

★ Your data is protected and will not be shared with third parties.

What You Can Do

Intervention Protocol Select an action below
01

Send a Strategic Suggestion

Offer ideas, press contacts, or legal support to strengthen the network backing Mrs. Glória Duarte.

Offer ideas, press contacts, or legal support to strengthen the network backing Mrs. Glória Duarte.

02

Sign the Support Manifesto

Your signature is not just a name — it is the official record that the world is watching CMOC's conduct.

Your signature is not just a name — it is the official record that the world is watching CMOC's conduct.

"I witness the situation of Glória Duarte and call on CMOC Group to immediately begin humanitarian negotiations."

Impact of your signature:

  • Permanent display on the digital "Wall of Conscience"
  • Inclusion in the Weekly Dossier sent to CMOC's Board
  • Notification to ESG rating agencies (Deloitte, MSCI)
03

Send an Email to Break CMOC's Silence

Send a pre-written message to CMOC's board, investors, and audit bodies with one click.

Send a pre-written message to CMOC's board, investors, and audit bodies — breaking corporate silence with a single click.

✓ Email copied to clipboard
04

File a Letter to the Chairman

Download the open letter addressed to Chairman Liu Jianfeng, demanding the company honor its commitments.

Download the open letter addressed to Chairman Liu Jianfeng, demanding the company honor its humanitarian and ESG commitments.

Mailing Addresses

Hong Kong Headquarters

CMOC Group Limited
29/F, China Resources Building
26 Harbour Road, Wanchai, Hong Kong
Attn: Chairman Liu Jianfeng

Brazil Operations

CMOC Brasil
Mina Boa Vista, Catalão - GO
ZIP: 75700-000

Send by registered mail with return receipt. Physical documents are mandatorily logged in the Chinese corporate compliance system.
05

Spread the Visceral Question

Confront the brand on social media with the question they cannot answer: "What if this were your mother?" (如果是你的母亲呢?)

Confront the brand on social media with the question they cannot answer.

WHAT IF THIS WERE YOUR MOTHER?

如果是你的母亲呢?

E se fosse sua mãe?

Official Hashtags

#BloodNiobium #CMOC #ESGScandal #JusticeForGloria #NiobioDeSangue
06

Check Your Risk Exposure Level

Identify how CMOC's violations expose you to risk.

Select your institutional profile to verify how CMOC's conduct impacts your interests and what mitigation actions are available.

Shareholders

(Cathay Fortune / CATL)
Risk in one sentence:

Equity diluted by an unprovisioned billion-dollar litigation

Required action:

Provision NOW or face personal derivative lawsuits

View Risk Level →

Investors

(BlackRock / Vanguard / China AMC)
Risk in one sentence:

Portfolio contaminated by undetected toxic ESG asset

Required action:

Immediate divestment or active board engagement

View Risk Level →

Auditors

(Deloitte / AFRC / PCAOB)
Risk in one sentence:

Signed statements omitting a material risk of US$ 3.2 BILLION

Required action:

Modify 2024 opinion or face AFRC/PCAOB sanctions

View Risk Level →

Regulators

(HKEX / SFC / CVM / SEC)
Risk in one sentence:

Systemic failure to supervise inside information disclosure

Required action:

Immediate preliminary inquiry and possible trading suspension

View Risk Level →

ESG Bodies

(MSCI / NOSA / Sustainalytics)
Risk in one sentence:

AAA rating built on systemic human rights violations

Required action:

Immediate downgrade to BB and full methodology review

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Clients

(Aerospace / Automotive / Defense)
Risk in one sentence:

Supply chain contaminated by "Blood Niobium" — LkSG/CSDDD violation

Required action:

Due diligence audit and contract suspension

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Chinese Government

(SASAC / NDRC / CCCPC)
Risk in one sentence:

State-owned company violates (Xiào) — the sacred Chinese filial value

Required action:

Immediate administrative intervention and compliance restructuring

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US Government

(DoD / CFIUS / USGS / NSC)
Risk in one sentence:

F-35 depends on niobium of conflicted, litigated origin

Required action:

CFIUS investigation and DoD critical supply chain audit

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Press

(FT / Bloomberg / Reuters / NYT)
Risk in one sentence:

Material story capable of redefining the global ESG debate

Required action:

Full investigation and formal request for CMOC's position

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